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Task guide

Reports to the FIC

How reports of suspicious and cash transactions are drafted, approved by a second person, filed with the Financial Intelligence Centre inside their time, and kept away from the client.

The Anti-Money Laundering Act, 2020 (Act 1044) asks the firm to report to the Financial Intelligence Centre (FIC) a transaction it suspects, and cash at or above the threshold the FIC sets. The system keeps both kinds of report under Settings, Compliance, FIC reports, read only by those who keep them.

Where a report comes from

  • A suspicious transaction report (STR) is drafted when the compliance officer decides a concern is to be reported. Deciding Report to the FIC drafts the report at once and starts its clock; where the concern named no party, the decision asks whom the report is about.
  • A cash transaction report (CTR) is drafted by itself when one payer's cash on one day reaches the firm's threshold, set under Settings, General, compliance, Cash transaction report threshold. Every cash receipt from that payer that day is added to it, and a receipt reversed afterwards comes off.
  • Draft report on the register drafts either kind by hand, naming the concern or the payer and the day.

The clock

A report is due within the hours the firm sets from the moment the firm knew, 24 by default for a suspicion (Suspicious transaction report due (hours)). The register opens soonest due first and marks a report Due soon within the FIC report warning (hours) and Overdue once past. The compliance officer is told as each point is reached.

The register of reports to the FIC, each against the time allowed to file it.
The register of reports to the FIC, soonest due first, with where each stands against its clock.

Draft, approve, file

  1. The preparer completes the report: the grounds in plain words, the amount where the suspicion has one, and the transactions it covers. A transaction is a receipt the firm recorded, chosen from the payer's, or a line written by hand for money that never passed through the firm.
  2. Mark ready sends it for approval.
  3. Approve is a second person's, never the preparer's, and asks for your password again.
  4. Download goAML gives the report as the XML the FIC's goAML portal takes; Download PDF gives a copy to keep.
  5. File with the FIC records how it went, the reference the FIC gave, when, and the FIC's acknowledgement where one came back. A filed report is final.

A ready report that is changed goes back to draft and needs approving again. Withdraw takes a report out with a reason; a filed report is corrected by a new one that names it.

A report to the FIC with its clock, grounds and filing.
A report to the FIC with its clock, grounds, transactions and history.

What the record keeps

The Transactions tab lists each transaction in its own currency and in cedis. The History tab lists every step taken, by whom and when, from the audit trail. Opening a goAML file, a PDF or the acknowledgement is itself recorded.

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